Form 15CA & 15CB Changes AY 2026–27: New Rules Under Income Tax Act 2025
The compliance framework for foreign remittances has undergone a significant shift with the introduction of the Income Tax Act, 2025. From AY 2026–27, the existing Forms 15CA and 15CB are being replaced by a more structured and digitally driven reporting system, aimed at enhancing transparency and accuracy in cross-border transactions. While the core objective of determining taxability and ensuring proper TDS deduction remains unchanged, the new regime introduces improved classification, automated validation, and streamlined filing procedures. These changes mark a move towards a more compliance-focused and technology-enabled tax system for all foreign payments made to non-residents.
What Changed in AY 2026–27 Under the Income Tax Act, 2025?
The introduction of the Income Tax Act, 2025 has brought a structural shift in the compliance framework for foreign remittances, effective from AY 2026–27. The most notable change is the replacement of Form 15CA and Form 15CB with newly introduced Forms 145 and 146, aligning the reporting system with a more modern, digital-first approach. While the underlying principle of determining taxability and ensuring proper TDS deduction on payments to non-residents remains intact, the format and reporting standards have been significantly upgraded.
Under the new regime, the government has focused on enhanced transparency, better data classification, and system-driven validation. The updated forms are expected to capture more detailed information about the remitter, recipient, nature of payment, and applicable tax provisions, reducing ambiguity and manual errors. This also enables better tracking of cross-border transactions by tax authorities.
Another important change is the strengthening of compliance through automation. The filing process is becoming more integrated with the income tax portal, allowing for real-time checks and validations, which minimizes incorrect filings and improves efficiency. Additionally, the exemption list under Rule 37BB has been expanded, and certain procedural relaxations have been provided in specific cases, especially for non-taxable transactions.
Overall, AY 2026–27 marks a transition from a documentation-based system to a technology-driven compliance ecosystem, where accuracy, accountability, and ease of reporting are given greater importance.
Replacement of Form 15CA & 15CB with New Forms 145 & 146 (AY 2026–27)
| Particular | Old System | New System (2026) |
|---|---|---|
| Forms | 15CA & 15CB | 145 & 146 |
| Applicable Law | Income Tax Act, 1961 | Income Tax Act, 2025 |
| Declaration Form | Form 15CA | Form 145 |
| CA Certificate | Form 15CB | Form 146 |
| Reporting Style | Basic details | Detailed & structured |
| Validation | Manual | System-based validation |
| Error Chances | Higher | Reduced |
| Processing | Slower | Faster & automated |
| Transparency | Limited | High |
| Effective Period | Up to 31 March 2026 | From 1 April 2026 |
Applicability of Form 15CA/15CB – Who Needs to File?
Form 15CA and Form 15CB are required in cases where a person (resident in India) makes a payment to a non-resident or foreign company. The primary objective is to ensure that tax has been properly determined and deducted (if applicable) before the money is remitted outside India.
Who is Required to File?
- Any Individual, Company, Firm, LLP, or Entity
making a foreign remittance to a non-resident (NRI) or foreign company - Remitter (Payer)
is responsible for filing Form 15CA as a declaration before making the payment - Chartered Accountant (CA)
must issue Form 15CB in cases where certification of taxability is required
When is Filing Applicable?
- When the payment is:
- Chargeable to tax in India, OR
- Requires verification of taxability under the Income Tax provisions
- Applicable for payments such as:
- Royalty
- Technical service fees
- Interest
- Commission
- Professional fees
- Any other income payable outside India
When It is NOT Required
- Payment is not taxable in India (covered under specific cases)
- Transactions covered under Rule 37BB exemption list
- Certain import payments and specified categories
- Individual remittances under Liberalised Remittance Scheme (LRS) (in specified non-taxable cases)
Applicability Based on Amount
| Situation | Form Required |
|---|---|
| Up to ₹5 lakh (in a financial year) | Only Form 15CA (Part A) |
| Above ₹5 lakh (taxable) | Form 15CA + Form 15CB |
| Non-taxable remittance | Form 15CA (Part D) |
| Covered under exemption list | No form required |
Important Practical Point
Even if no tax is payable, Form 15CA may still be required to declare the nature of remittance. Banks (Authorized Dealers) generally do not process foreign payments without these forms, ensuring compliance with tax regulations.
Cases Where Form 15CA & 15CB Are Not Required (Updated List)
- Rule 37BB Exemption Transactions
- If remittance falls under the specified 33 exempt categories, no Form 15CA or 15CB is required
- Import of Goods
- Payments made for importing goods from outside India are fully exempt
- Travel Expenses
- Foreign remittances for tour, travel, hotel, or ticket booking are not required to file forms
- Education Expenses Abroad
- Payments like tuition fees, admission fees, exam fees are exempt
- Medical Treatment Abroad
- Remittance for medical expenses, hospital fees, treatment is exempt
- Personal Remittances
- Payments such as gifts, donations, maintenance of relatives abroad are not required
- Freight & Shipping Charges
- Payments related to transport, shipping, logistics services are exempt
- Non-Taxable Remittances
- If the payment is not chargeable to tax in India:
- Form 15CB → Not required
- Form 15CA → Only Part D (in some cases)
- If the payment is not chargeable to tax in India:
- LRS (Liberalised Remittance Scheme) Cases
- Individual remittances under LRS where:
- No RBI approval required
- Payment is non-taxable
→ No 15CA/15CB required
- Individual remittances under LRS where:
- Government / Notified Exempt Payments
- Payments to government bodies or notified entities may be exempt
- Small Value + Non-Taxable Cases
- If amount is low and transaction is non-taxable → minimal or no compliance
Expanded Exemption List Under Rule 37BB (2026 Changes)
Under the updated compliance framework applicable from AY 2026–27, the government has expanded the exemption list under Rule 37BB, increasing the number of specified transactions where Form 15CA and Form 15CB are not required. This change is aimed at reducing unnecessary compliance burden for routine and non-taxable foreign remittances, while allowing tax authorities to focus on high-risk or taxable transactions.
Earlier, the exemption list covered 28 categories, but under the revised rules, it has been expanded to 33 categories, providing relief to individuals and businesses engaged in common cross-border payments. These transactions are generally considered non-taxable in India or involve standard outward remittances, where the risk of tax evasion is minimal.
The expanded list broadly includes payments such as:
- Import of goods and related payments
- Travel, education, and medical expenses abroad
- Personal remittances like gifts, donations, and maintenance of relatives
- Freight, shipping, and airline-related charges
- Business-related reimbursements and certain service payments
A key objective of this expansion is to streamline the remittance process through banks (Authorized Dealers) by eliminating the need for repetitive documentation in low-risk cases. This ensures faster processing, reduced paperwork, and improved ease of doing business, especially for individuals making routine payments under schemes like LRS.
However, it is important to note that:
- The exemption applies only if the transaction clearly falls within the specified categories
- Banks may still require supporting documents to verify the nature of remittance
- If a transaction is taxable or not clearly covered, compliance with Form 15CA/15CB (or new Forms 145/146) will still be mandatory
Overall, the expansion of the Rule 37BB exemption list reflects a shift towards a risk-based and taxpayer-friendly compliance system, where genuine transactions are simplified while maintaining strict control over taxable foreign remittances.
Digital Transformation in Foreign Remittance Reporting (2026)
The introduction of the Income Tax Act, 2025 marks a significant shift towards a fully digital and technology-driven compliance system for foreign remittance reporting, effective from AY 2026–27. The replacement of traditional Forms 15CA and 15CB with new, system-integrated Forms 145 and 146 reflects the government’s intent to modernize tax procedures and reduce manual intervention.
Under this digital transformation, the reporting process is becoming more automated, accurate, and transparent. The new system is expected to be tightly integrated with the income tax portal, enabling real-time validation of data, including PAN details, remitter information, nature of payment, and applicable tax provisions. This reduces the chances of incorrect filings and ensures that errors are identified instantly during submission.
Another key improvement is the introduction of structured data reporting, where taxpayers are required to classify remittances under predefined categories. This enhances clarity and allows tax authorities to track cross-border transactions more efficiently, helping in better risk assessment and compliance monitoring.
For professionals like Chartered Accountants, the system introduces standardized formats and digital certification processes, making the issuance of certificates more consistent and traceable. At the same time, taxpayers benefit from faster processing, reduced paperwork, and improved user experience.
Overall, the 2026 transformation moves foreign remittance compliance from a largely manual and document-based system to a smart, integrated, and digitally verified ecosystem, ensuring greater accountability while simplifying procedures for genuine transactions.
Key Differences Between Old Forms (15CA/15CB) vs New Forms (145/146)
| Particular | Old Forms (15CA / 15CB) | New Forms (145 / 146) – 2026 |
|---|---|---|
| Applicable Law | Income Tax Act, 1961 | Income Tax Act, 2025 |
| Form Type | 15CA (Declaration) / 15CB (CA Certificate) | 145 (Declaration) / 146 (CA Certificate) |
| Effective Period | Up to 31 March 2026 | From 1 April 2026 |
| Reporting Format | Basic & semi-structured | Detailed & fully structured |
| Data Entry | Manual-heavy | System-driven & guided |
| Validation | Limited checks | Real-time system validation |
| Error Chances | Higher | Significantly reduced |
| Technology Use | Basic portal filing | Advanced digital integration |
| Transparency | Moderate | High transparency |
| Processing Time | Slower | Faster & automated |
| Tracking | Limited tracking | Better transaction tracking |
| Compliance Level | Standard | More strict & accurate |